Privacy Notice True Leasing Company Limited

Introduction

True Leasing Company Limited (the “Company”), as the data controller of personal data, realizes the significance of personal data protection, and you, as the data subject and the Company’s customer, wish to be assured of security of your personal data. Therefore, the Company has prepared this Privacy Notice to address how the Company has collected, used and disclosed your personal data, as the data subject. This Privacy Notice is intended to provide details and procedures for personal data management. The Company may update or revise this Privacy Notice to be in line with its provision of services and legal principles. Should this Privacy Notice be changed, revised, supplemented or updated, the Company shall post such change, revision, supplement or update on its website.

This Privacy Notice forms an integral part of the terms and conditions for use of goods and services, access to, use of contents, features, technology or functions available on this website as well as applications and any other related services of the Company which are currently available and/or to be available in the future.

1. Definitions

“personal data” refers to any information relating to a person who can be identified, directly or indirectly, which is classified as general personal data and/or sensitive personal data;

“general personal data” refers to any information relating to a person who can be identified, directly or indirectly, such as, customer data, news or information relating to any identifier of a person, e.g., first and last names, identification card number, identification card image, age, date of birth, gender, bank account number, credit card number, address, telephone number, e-mail, education, work experience, photograph, motion image, sound, financial information, credit information, username and password, location information and movability etc.

“sensitive personal data” refers to any personal data relating to race, nationality, religion, political opinion, criminal records, genetic data, health data, disability, biometric data or any other data which affect the data subject in the same manner as prescribed by the Personal Data Protection Committee;

“location information and movability” refers to GPS information (Global Positioning System), car location, Geographic Coordinates, travel information, date and time;

“data controller” refers to True Leasing Company Limited, which shall have the power and authority to make decisions relating to the collection, use or disclosure of personal data;

“processing of personal data” refers to any collection, use and disclosure of personal data.

“Personal Data Protection Act” refers to the Personal Data Protection Act B.E. 2562 (2019) and its amendment.

2.Sources of Personal Data

The Company will collect your personal data from the following channels:

2.1 The Company directly obtains your personal data when the Company collects your personal data from the procedures for provision of services as follows:

2.2.1 At the step of application for services or submission of a request for exercise of rights with the Company;

2.2.2 From your voluntary completion of a survey or e-mail correspondence or other communication channels between you and the Company;

2.2.3 From the use of services or products relating to services;

2.2.4 From the use of the Company’s website via your browser’s cookies;

2.3.5 From such purchase of goods and services via online channels, e.g., the Company’s website, online platform, booth, promotional activities of the Company.

2.2 The Company obtains your personal data from sources other than you, such as personal data searches through websites or inquiries made with third parties; in this case you will be notified of the personal data collection by the Company without delay, i.e., not later than 30 (thirty) days from the date on which the Company collects personal data from the aforementioned sources, and the Company will proceed to obtain your consent to collect such personal data, except where the Company is not required by law to obtain the consent from you.

3. Objectives and Basis of Processing of Personal Data

3.1 Objectives of Processing of Personal Data

The Company processes your personal data for the following objectives:

3.1.1 For the purpose of ensuring that the use of services is smooth and complies with the applicable laws, rules and regulations and to perform its obligations under the applicable laws and regulations currently in force and/or to be revised in the future.

3.1.2 For the purpose of your authentication or identification upon use of the Company or business partners of the Company’s services, e.g., booking, booking confirmation, review of your previous bookings, data transmission to insurance companies, data transmission to financial service providers, etc. including the visitors to request access to the Company’s office areas;

3.1.3 For the purpose of enhancing the efficiency and improving the provision of various services, e.g., customer relations service, responses to the requirements, handling of your application for services, etc.;

3.1.4 For the purpose of communication via telephone, SMS, MMS, e-mail, postal service and/or any channels to make inquiries or inform or survey or provide any other news and updates relating to the Company’s services as necessary;

3.1.5 For any other purposes relating to the Company’s business operations, e.g., for study, research, statistics, development of services, analysis of marking plan, marketing activities or related target advertising, including provision of contents, advertisements and public relations, activities and promotions, as well as advice as appropriate to ensure that the services match your interest;

3.1.6 For the purpose of facilitating notifications, delivery of documents and/or payment of service charges, fees relating to goods and services to you;

3.1.7 For execution and/or performance of contracts, including compliance with the conditions of services of the Company;

3.1.8 For after sales service, provision of services per your request, answers to questions, support for use, provision of information, acceptance of complaints and resolution of problems and issues;

3.1.9 For taking photos or recording on video or CCTV in our events for monitor who are in our areas to support to protection of our properties and safety, to investigate unauthorized physical access and accident or crime.

3.1.10 For recording location information and movability and/or motion images on car Dashcam for inspecting any situation and/or used as evidence when an accident or a crime occurs, including inspecting travel routes, the driving and driving behavior of the driver;

3.1.11 For recording information, conversation and/or any communication between you and the Company, e.g., e-mails, telephone interviews, etc., for the purpose of development and management of communications and/or provision of the Company’s services;

3.1.12 For settlement of disputes, recovery, debt collection and enforcement;

3.1.13 For safety or suppression of harm to a person’s life, body or health;

3.1.14 For other objectives as empowered by law for collection, use or disclosure without obtaining your consent, as the data subject;

3.1.15 For compliance with the policies within the Company, its group, affiliated companies, subsidiary companies and businesses;

3.1.16 For provision of services of the Company’s group, affiliated companies, subsidiary companies and businesses, strategic partners of the Company and/or any other legal entities which the Company is a contractual party or has legal relationship under the law, whether in Thailand or abroad.

3.1.17 For management relationships between the Company and you related to accounting.

Should the Company subsequently change the objectives of its processing of personal data, the Company shall keep you updated via the Company’s website at https://www.trueleasing.co.th

3.2 Basis of Processing of Personal Data

The Company proceeds with the processing of your personal data under the following bases:

3.2.1 Contractual Basis

The Company shall process your personal data as necessary for execution and/or performance of contract, and as such, for the processing of personal data on contractual basis, the Company is not required to obtain consent prior to processing of personal data.

3.2.2 Consent Basis

The Company shall obtain your consent, as the data subject, prior to processing of personal data on this consent basis.

• The Withdrawal of the Consent

Should you wish to withdraw your consent, you may do so via the Company’s contact channels in this Clause 5. However, the withdrawal of consent shall not affect the processing of personal data to which you have previously given consent under the law.

• Consequences of Without the Consent or the Consent Withdrawal

The Company hereby informs you of potential impact from the withdrawal of your consent or without the consent of the data subject as follows:

1)Your rights to use certain services of the Company may be restricted or the services to be received from the Company may be less convenient.

2)The Company may be unable to provide certain services or offer certain products to you should such personal data be essentially required for the Company’s provision of services to you.

3.2.3 Legal Obligation Basis

The Company is necessary required to process your personal data on the basis of its legal obligations, e.g., the Computer Crime Act, the Cyber Security Act, the Personal Data Protection Act, the Electronic Transaction Act, the Anti-Money Laundering Act, the Civil and Commercial Code, the Penal Code, the Revenue Code, etc., including court orders, judgments or orders of any other government agencies and/or any other laws currently in force and/or to be revised in the future.

3.2.4 Legitimate Interest Basis

The Company is necessary required to process your personal data on the basis of legitimate interests. It is noted that the processing of personal data on this basis is of benefit to you, third parties and/or legitimate interests of the Company, except where such interests are overridden by your basic rights. Such personal data to be processed by the Company on the basis of legitimate interests include:

(a) Your personal data shall be shared within the Company for execution of the Company’s work procedures, whereby the Company will forward your personal data among various operation units within the Company which involves the processing of your personal data in accordance with the Company’s operation procedures;

(b) The processing of personal data of third parties is for the purpose of reviewing the Company’s welfare to staff and their families, whereby the processing of personal data is for legitimate interests of the data subjects, who are third parties without prejudice to their rights of privacy.

3.2.5 Vital Interest Basis

The Company is necessary required to process your personal data on the basis of vital interests as protection or suppress the danger to the life, body, or health of the data subject and/or the third party and/or the employees of the Company.

3.2.6 Historical Document, Research and Statistics Basis

The Company is necessary required to process your personal data on the basis of historical document, research and statistics for the purpose relating to the preparation of the historical documents or the archives for public interest, or research or statistics, in which the suitable measures to safeguard your rights and freedoms are put in place.

In case of collecting sensitive personal data, the Company must explicitly request your consent either prior to or at the time of collection except where the Company is not required by law to obtain the consent from you.

4. Description and Period of Personal Data Storage

4.1 Description of Personal Data Storage

The Company stores personal data in the form of hard copy and/or soft copy by electronic and/or voice recording means, with efficient security measures to prevent any loss, unauthorized or undue access to, use, modification, revision or disclosure of personal data.

4.2 Period of Personal Data Storage

The duration for which the Company collects your personal data will be either one of the following:

4.2.1. The personal data will be retained for the periods stipulated by laws specifically relevant to retention of the personal data such as the Accounting Act., Anti-Money Laundering Act., Act on Commission of Offence Relating to Company, the Revenue Code, etc.

4.2.2. In cases where the retention period for personal data is not specified by relevant laws, the Company shall keep your personal data only for such period as necessary for the above objectives.

4.2.3. The Company will collect and retain your personal data throughout the duration of the contract and after contract termination for a period not exceeding 10 (ten) years or during the existence of such contract or legal relationship between you and the Company or within the timeframe for exercise of rights of claim under the law by contractual parties or enforcement of rights under the law or challenge to any rights of claim under the law by the Company or court proceedings until the end of such action.

Upon the lapse of the period of personal data storage or when the Company is no longer entitled or unable to claim the basis of processing of your personal data, the Company shall erase or destroy or render such personal data unidentifiable in respect of the data subject within a reasonable period of time.

5. Contact Channels

You may contact the Company or its Data Protection Officer (DPO) to submit any request regarding your personal data to exercise such available rights via the following channels:

5.1 Information of the Data Controller

Company : True Leasing Company Limited

Contact Address : 18 True Tower, Ratchadaphisek Road, Huaikhwang, Bangkok, Thailand, 10310

Contact Channels : Call Center: 1279

Email : Autorentalbytls@truecorp.co.th

https://www.trueleasing.co.th

5.2 Information of the Data Protection Officer

Name : Kamonwan Hundee

Contact Address : 616 Luang Pang Road, Thapyao, Lat Krabang, Bangkok, Thailand, 10210

Contact Channels : Telephone: 02 859 7975

Email : dpotrueleasing@wg.co.th

https://www.trueleasing.co.th

6. Rights of Data Subjects

The Company may collect, store, use, distribute or take any other arrangements relating to your personal data on the legal basis of processing of personal data under the Personal Data Protection, pursuant to which you shall have the rights to take the following arrangements:

6.1 Right to withdraw consent

You are entitled to withdraw your consent which has been given to the Company in the processing of personal data at any time during the period your personal data remains in the Company’s possession unless there is a restriction of the withdrawal of consent by law, or the contract which gives benefits to the data subject.

However, the withdrawal of consent shall not affect the collection, use, or disclosure of personal data that the data subject has already given consent legally.

Consequences of the Consent Withdrawal

The Company hereby informs you that any incomplete personal data or without the consent to the processing of personal data or withdrawal of the consent may restrict your rights to use certain services of the Company or the services to be received from the Company may be less convenient or may render the Company unable to provide any services or offer certain products to you should such personal data be necessary for the Company’s provision of services to you.

6.2 Right of access to personal data

You are entitled to access and request a copy of your personal data which are under the Company’s responsibility, and also request the Company to disclose how your personal data have been obtained without consent to the processing of personal data.

6.3 Right to rectification of personal data

You are entitled to request the Company to rectify or add your personal data to be correct, up-to-date, complete and not misleading.

6.4 Right to erasure and destruction of personal data

You are entitled to request the Company to erase or destroy your personal data kept by the Company or render such personal data unidentifiable in respect of the data subject, in any of the following events:

(a) The personal data is no longer necessary to retain it for the purposes for the personal data is collected, used or disclosed;

(b) You withdraw your consent and the Company is not authorized to continue processing of personal data;

(c) You exercise the right to object the processing of personal data and the Company is unable to find grounds for refusal of your objection;

(d) In the case of the processing of such personal data is unlawful.

6.5 Right to suspension of use of personal data

You are entitled to request the Company to temporarily suspend the use of your personal data should the Company be in the course of fact-finding or review of your objection. In addition, should you be entitled to request the Company to erase or destroy your personal data, you may request the Company to suspend the use of your personal data instead of erasure or destruction.

6.6 Right to data portability

You are entitled to request to obtain or request the Company to send or transfer your personal data to another data or at the request of other authorities.

6.7 Right to object to processing of personal data

You are entitled to object to the storage, use, collection, and disclosure of personal data relating to you should such personal data collected by the Company with the exemption from the data subject’s consent are necessary for lawful or legitimate interests or such personal data are collected, used or disclosed for direct marketing or research.

6.8 Right to complain

In the event where the Company or its staff breach or fail to comply with the Personal Data Protection or any notifications issued by virtue of this Act. In this connection, you may file a complaint with the Office of the Personal Data Protection Committee.

The Company shall collect, use and disclose personal data of a minor under the age of 10, incompetent person and/or quasi-incompetent person only upon receipt of consent from the legal representative, guardian or curator (as the case maybe). In case of the Company collect, use and disclose personal data from the foregoing persons without consent as prescribed by law. The Company shall erase such personal data, except where the Company is legally entitled to proceed with such collection, use and disclosure.

If you wish to exercise the rights in Clause 6.1 to Clause 6.7 mentioned above, you can request an application for exercise of rights of the data subject at the office of the Company or the Data Protection Officer or download applications through the Company’s website.

7.Categories of persons or agencies to whom the collected personal data may be disclosed

The Company may disclose such collected personal data to any persons, legal entities and agencies as listed below.

7.1 Companies in the group, affiliated companies, subsidiary companies and businesses;

7.2 Service providers of the Company: The Company may disclose your personal data to any service providers of the Company, provided that such service providers shall use your personal data only to the extent permitted by the Company only on a need-to-know basis:

- Professional consultants, e.g., financial advisors, legal consultants;

- Basic infrastructure and information technology service providers;

- Data storage service providers, including cloud service providers;

- Marketing service providers, including data and statistical service providers;

- Advertising, public relations and communications service providers;

- Service providers relating to payment networks and systems;

- Payment agencies;

- Financial institutions whose services are used by the Company to provide services to you;

- Data verification service providers;

This includes any other legal entities which the Company is a contractual party or has legal relationship under the law, whether in Thailand or abroad, and such persons or legal entities may be located in any country where the personal data protection standards may not be sufficient, although the Company shall ensure that such persons or legal entities have a secured personal data storage system;

7.3 Strategic partners of the Company with strategic partnership arrangements with the Company;

7.4 Assignees of rights and/or obligations from the Company;

Should the Company wish to assign its rights and obligations, including partial or entire business, business merger, its shareholding restructuring, it is necessary for the Company to disclose your personal data to the assignees (including potential assignees);

7.5 Persons or agencies as prescribed by law;

This is required by the applicable laws, rules and regulations, as well as orders of government agencies, regulatory bodies or court orders.

8. Collection and Use of Personal Data in the Form of Cookies

The Company may access personal data in respect of your interest and/or preference and/or your use of website by using cookies on the Company’s website and applications, so as to enable the Company to offer services in response to your requirements as much as possible. Such personal data shall be kept in the form of cookies. In order for the Company to send or show any news and information regarding services or offers from the Company to you on the website, it is necessary for the Company to keep and use such data relating to your visit to the website. Such data shall be kept in the form of cookies, which are a small element of data sent by the website to your browser and recorded in your computer and/or communication devices, e.g., tablet, smartphone, etc. Upon your next visit to the Company’s website, these cookies will enable the Company to properly manage your preference in order to facilitate your return to visit the Company to be more convenient. Furthermore, cookies are also used to measure online traffic, change the contents in accordance with your past and current usage or for the purpose of advertising and public relations. However, you may change your browser settings to disable the Company’s use of cookies. In this regard, you may read more details regarding cookies at http://allaboutcookies.org/.

The Company may contact with any third party advertising networks which collect IP addresses and other data by using cookies to keep records of the operations of the web server, and such third parties may use such data for advertising products and services in line with your interest (including advertising for other companies not related to the Company), and as such, you may see these advertisements on any other websites. These procedures help the Company manage and monitor its marketing achievements. However, you may choose not to accept data in those advertising networks through their respective network systems.

9. Use of personal data for original purposes

The Company is entitled to continue collecting and using your personal data, which has previously been collected by us before the effectiveness of the Personal Data Protection Act in accordance with the original purposes. Should you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time via the Company’s contact channels in this Clause 5.

10. Privacy Notices of Other Websites

This Privacy Notice applies only to the services and use of the Company’s website. Should you visit any other website, even via any link available on the Company’s website, you should read and comply with the privacy notice of that website separately from the Company. In this respect, the Company shall not be responsible for any contents of such website or treatment of personal data by such website.

11. Security of Personal Data

The Company realizes the significance of security of your personal data, and as such, arranges for appropriate security measures for personal data in line with confidentiality of personal data, and restricts access to your personal data by the Company’s unconcerned staff, employees and agents to prevent any loss, unauthorized or unlawful access thereto, destruction, use, modification, revision or disclosure thereof.

In cases where the Company has engaged an agency or a third party to perform work related to the collection, use or disclosure of personal data of the data subject, it shall require the agency or the third party to keep the personal data confidential and secure, and to prevent the collection, use or disclosure of such personal data for any purposes other than specified in the scope of engagement or for any unlawful purposes.